HMDA Reporting for Property Purchased w/Cash

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Question:

A question was previously posted in regards to HMDA Reporting for Property Purchased with Cash. Specifically, the question states: "We have a business customer that purchases property for cash, then applies for a mortgage loan using the property as collateral. Is this a HMDA reportable loan or not; if so, what is the purpose? He is not improving the properties. Should we consider this a refinance?" The answer provided states that it is not a refinance. However, it does not specify if its considered a purchase or if it is not HMDA reportable at all. Please let me know if this is HMDA reportable and if so, if it considered a purchase.

Answer:

This would not be a purchase because the customer previously purchased the property. It is not a refinance because the loan is not paying off a prior lien. The transaction is not reportable for HMDA purposes.

First published on BankersOnline.com 9/3/12